Explores modern departures from the traditional approach. Substantively, the chapters focus on party autonomy, the Second Restatement, interest analysis, and the "better law" approach. Also includes the recognition of judgment and selected problems in family law. Presents conflicts between state and federal law. Exposes students to the core set needed to understand the place of conflict of laws analysis in international law.

Preface

v

Acknowledgments

ix

Table of Cases

xix

Table of Authorities

xxxiii

PART I. CHOICE OF LAW: THE BASIC MODEL

The Traditional Approach to Choice of Law

2

(87)

Traditional Theory: A Survey of Jurisdiction-Selecting Rules

2

(36)

Traditional Practice: A Survey of Escape Devices

38

(44)

Pleading and Proving Foreign Law

82

(7)

Modern Approaches to Choice of Law

89

(215)

Statutory Solutions

89

(6)

Party Autonomy and the Rule of Validation

95

(20)

Interest Analysis

115

(83)

Place of the Most Significant Relationship

198

(25)

The Better Law

223

(16)

Problems Old and New

239

(65)

The Constitution and Choice of Law

304

(62)

The Limits of Legislative Jurisdiction

304

(38)

The Obligation to Provide a Forum

342

(11)

Unconstitutional Discrimination in Choice of Law

353

(13)

PART II. OTHER APPLICATIONS

Jurisdiction of Courts

366

(84)

Jurisdiction Based on the Relation of the Litigation to the Forum

367

(38)

General Jurisdiction

405

(11)

Attachment Jurisdiction

416

(19)

Transient Jurisdiction

435

(15)

Recognition of Judgments

450

(91)

Special Problems of Choice of Law, Jurisdiction, and Recognition of Judgments in Divorce, Interstate Child Custody, and Decedents' Estates

541

(82)

Divorce

541

(46)

Child Custody

587

(32)

Decedents' Estates

619

(4)

Conflicts Between Federal and State Law

623

(104)

Federal Question Jurisdiction

623

(28)

The Erie Doctrine

651

(49)

Choice of Law in Federal-Court Cases Involving State-Created Rights

700

(4)

Federal Common Law

704

(12)

Federal Law in State Courts

716

(11)

International Conflicts

727

(112)

The Scope of Legislative Jurisdiction: ``Extraterritorial'' Regulation

727

(59)

The European Perspective

786

(14)

The Act-Of-State Doctrine

800

(17)

Recognition of Judgments

817

(12)

APPENDICES

A. The Constitution of the United States

829

(4)

B. Title 28, United States Code

833

(6)

Index

839

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